due process

Issues

Civil forfeiture statutes allow law enforcement agencies to seize personal property without a warrant if the property is connected to illegal drug activity. A group of Chicago residents whose vehicles were seized organized a class action challenging the Illinois civil forfeiture statute on constitutional grounds. Specifically, they alleged that civil forfeiture improperly deprived them of due process because of the extensive delay the statute allowed before requiring actual civil forfeiture proceedings. After the trial court dismissed their complaint, the Seventh Circuit held the statute unconstitutional. The Supreme Court granted certiorari and now has an opportunity to clarify exactly what process is due to property owners facing statutory civil forfeiture proceedings.

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The Supreme Court will decide whether the holding in Johnson v. United States, 135 S. Ct. 2551 (2015), makes the residual clause in section 4B1.2(a)(2) of the United States Sentencing Guidelines void for vagueness and, if so, whether this new rule gives relief to Petitioner Travis Beckles by retroactively applying to collateral cases challenging federal sentences under § 4B1.2(a)(2)’s residual clause. Beckles argues that § 4B1.2(a)(2)’s residual clause is void for vagueness under Johnson because the residual clauses in both cases are identical, and the Court held that the clause in Johnson was void for vagueness. Beckles also asserts that this new rule applies retroactively under the Court’s test in Teague v. Lane, 489 U.S. 288 (1989). Respondent the United States argues, however, that Beckles’s new rule would not apply retroactively because it is a procedural rather than a substantive rule, and thus the Court should reject his request at this threshold. The United States further argues that if the Court does reach the merits, § 4B1.2(a)(2)’s residual clause is not void for vagueness with respect to those applications expressly specified in the commentary to § 4B1.2(a)(2) because this commentary clarifies the otherwise vague guideline. This case will address whether retroactive resentencing for “career offenders” will burden the federal system and will clarify the advisory nature of the Sentencing Guidelines in terms of due process concerns.

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In this case, the Supreme Court will decide whether the delay between a criminal defendant’s guilty plea and sentencing violates the Speedy Trial Clause of the Sixth Amendment. Betterman argues that the fundamental nature of the Speedy Trial Clause, as well as the Supreme Court’s precedent, supports applying the clause to delays in a defendant’s sentencing. Montana counters that the Speedy Trial Clause was never intended to apply to sentencing and that the Supreme Court’s precedent supports this position. The outcome of this case could affect the ability of convicted defendants to mount an adequate defense at sentencing.

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This case asks the Supreme Court to determine whether a 30-day filing deadline serves as a flexible procedural rule or a limitation on the Tax Court’s jurisdiction. Petitioner Boechler argues that the filing deadline is a procedural rule that is subject to the remedy of equitable tolling to effectively grant extensions in appropriate circumstances. Respondent Commissioner of Internal Revenue counters that the 30-day filing deadline proscribes a jurisdictional prerequisite, limiting the Tax Court’s jurisdiction to only those petitions that were timely filed within the 30-day period. The outcome of this case has important implications for the treatment of tax law, interpretation of filing deadlines within interconnected statutory schemes, and disparate outcomes for low-income taxpayers.

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This case asks the Supreme Court to determine whether a “violent felony” under the Armed Career Criminal Act of 1984 includes crimes in which an individual used force recklessly. Petitioner Charles Borden asserts that the United States Court of Appeals for the Sixth Circuit incorrectly held that committing a crime with a mens rea of recklessness constitutes a violent felony because the mental state of recklessness does not include the intention or knowledge that would satisfy the requirement of using force “against the person of another.” Respondent United States counters that a mens rea of recklessness satisfies the element because the focus is on the “use” of the physical force, which does not discern between mental states. The outcome of this case has important implications for criminal procedure, due process rights, and the necessary interpretation of the text of the ACCA.

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A jury convicted Edmund Boyle of racketeering and racketeering conspiracy under the Racketeer Influenced and Corrupt Organizations Act ("RICO") and sentenced him to 151 months in prison for his participation in a string of bank robberies. Boyle appealed his conviction to the Second Circuit, arguing that the United States misinterpreted the scope of an "enterprise" under RICO. Boyle argued that RICO did not apply because the United States could not prove that the group of bank robbers was an enterprise if it could not prove the group had a formal, ascertainable structure. The United States argued that the individuals were an enterprise and that they did not need to prove a formal structure existed under RICO. The Second Circuit affirmed the conviction. The Supreme Court granted Boyle's petition to determine a three-way circuit split over what constitutes an enterprise under the RICO statute. The outcome of this case will affect the scope of the RICO Act and will impact the ability of law enforcement to prosecute individuals under the RICO Act.

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John Stumpf and his accomplice, Clyde Wesley, were convicted of the murder of Mary Jane Stout. Stumpf, in his appeal to the Supreme Court, argues that the prosecutor unfairly used inconsistent theories to prove that both he and Wesley were guilty for the murder – -- even though a single shot was used to kill Stout. Stumpf thus claims his rights under the Due Process Clause of the Constitution were violated. Stumpf also argues that his guilty plea at trial was entered unknowingly and involuntarily because he did not understand the elements of the crime. The Supreme Court, in making its decisions, will have to address the role of the prosecutor in a criminal proceeding, the rights of the defendant under the Due Process Clause, and the extent to which a defendant can later invalidate his earlier plea of guilty.

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In this case, the Supreme Court will determine whether courts have specific jurisdiction over defendants only when the case arises out of conduct that is causally connected to a defendant’s in-state conduct. The case comes before the Supreme Court after Bristol-Myers Squibb was sued in California for manufacturing a defective anticoagulant, despite having manufactured the anticoagulant in New Jersey and having only a transient connection with California. Bristol-Myers Squibb argues that the California court lacks power to adjudicate this case, because the company’s conduct in California is not causally connected to the plaintiffs’ injuries. California Superior Court, on the other hand, argues that specific jurisdiction does not require proof of causation. Much is at stake in this action: some assert that California’s victory would result in gross injustice to defendants; others claim that BMS’s victory would cause judicial resources to be squandered with duplicative litigation.

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This case asks the Supreme Court to determine whether the government complies with the Immigration and Nationality Act (8 U.S.C. § 1229(a)) (“INA”) when it provides notice of deportation proceedings in a separate document from their date and time. Under 8 U.S.C. § 1229(a), the government must provide “written notice” to undocumented immigrants who are subject to deportation. This “written notice” is provided in a document called a “notice to appear” (“NTA”) and must include the “time and place” of the proceedings under 8 U.S.C. § 1229(a)(1)(G)(i). However, the government routinely sends two documents: one NTA to alert the immigrant about the removal proceedings, and another Notice of Hearing (“NOH”) to communicate the time and place of the hearing. Campos-Chaves argues that this scheme violates the INA because the statute requires this information to be provided in one document. The United States argues that it complies with the INA because its disjunctive language permits dual-document notice and because a curative NOH overcomes a defective NTA. This case touches on important questions regarding fair notice to immigrants in deportation proceedings and judicial economy.

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The Supreme Court will decide whether a court, in deciding not to grant a discretionary post-judgment sentencing revision under 18 U.S.C. § 3582(c)(2) in proportion to the amended Federal Sentencing Guidelines, must provide an explanation or can issue its decision through a preprinted form order containing standardized language. The Fourth, Fifth, and Tenth Circuits have held that § 3582(c)(2) does not require a judge to provide an explanation when refusing to grant a motion for a proportional sentencing reduction in accordance with the amended Guidelines. The Sixth, Eighth, Ninth, and Eleventh Circuits, however, have found that judges are required to explain sentencing revision decisions. Petitioner Chavez-Meza argues that a judge must provide some explanation for a disproportional sentencing reduction when the reasons for the decision are not apparent from the record. Respondent United States argues that judges can use preprinted forms when granting sentencing revisions that are disproportional to the Guideline revisions, as long as the form order contains standardized language stating that the court has considered the policy and applicable factors set forth in 18 U.S.C. § 3553(a). This case will clarify the extent to which application of the amended Guidelines reflects a bipartisan shift away from punitive sentences for drug offenses.

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